Memorandum submitted by the Sustainability
Council of New Zealand (GEO 08)
Although governments have a duty under the UN
Framework Convention on Climate Change (FCCC) to avoid "dangerous"
climate change, the treaty does not specify what concentration
of greenhouse gases would constitute a safe level. In absence
of this, international negotiations have operated on the basis
that limiting the average rise in global temperatures to 2°C
will be sufficient. It has also been widely assumed that if the
concentration can be stabilised at 450 parts per million
this would provide a 50% chance of holding the temperature rise
below that 2°C limit.
A 50% chance of avoiding dangerous outcomes
is a very low level of protection for an intergenerational endowment.
Yet international negotiations to date have implicitly targeted
concentrations of 450 ppme and above. Further, the modelling
behind these estimates excludes what are termed "slow"
feedback effectschanges to ice sheets and vegetation.
If climate models are required to deliver an
appropriately high chance of keeping within the 2°C target,
and also to account for slow feedback effects, the world's "carbon"
budget is already overspent. Citing a changed understanding of
the timescale for slow feedback effects, James Hansen of NASA
last year revised down his estimate of a "safe" concentration
for CO2 alone to 350 ppmmeaning less
than 400 ppme for all gases. This is below today's level
and would require that a significant volume of greenhouse gases
be extracted from the atmosphere.
In contrast, the plan to confront global warming
that is the current focus of international negotiations is based
simply on cutting emissions. It assumes that the atmosphere can
absorb sufficient additional carbon to allow a prompt but unhurried
transition to a low carbon economy. However, a truly low risk
and precautionary plan would require not just cutting emissions
but also reducing the existing concentration by extracting CO2 from
Avoiding dangerous climate change will require
a new plan that makes use of a mixture of options. There is a
clear hierarchy of preferred measures:
1. Abatement: reducing greenhouse gas
2. Sequestration: removing greenhouse
gases from the atmosphere; and
3. Reflection: limiting warming by reflecting
or blocking sunlight.
Immediate options for large-scale sequestration
are biologically based and dominated by afforestation, while the
capture of CO2 from the air by chemical reaction
is seen as the key emerging technology.
If all the sequestration capacity estimated
to be available were used together with responsible rates of abatement,
this would be almost enough to absorb both new and historic emissions
at a rate sufficient to deliver a 380 ppme concentration
by 2050. While new techniques may well raise future estimates
of the available capacity, it remains uncertain what proportion
of the technical potential could be accessed in practice and the
extent to which financial constraints would limit uptake.
Further, if the concentration is already above
a safe level and it will take many years to reduce this significantly
under any plan, there is the risk that significant feedback effects
could be triggered in the meantimesuch as the release of
additional greenhouse gases from thawing permafrost. A precautionary
plan would therefore also need to investigate reflection options.
Such a plan would place emphasis on managing
risk, especially feedback effects. These are triggered by what
might be termed the Apparent Concentrationthe warming effect
felt today as compared to that which can ultimately be expected.
In particular, half the warming effect of the greenhouse gases
added to the atmosphere since the industrial revolution is suppressed
by aerosol pollutants and other agents that reflect sunlight.
It will be important to separately manage the net effect of these
two, the Apparent Concentration, while maintaining a long-term
focus on reducing the greenhouse gas concentration.
Reflection options receiving serious attention
include injecting aerosols into the stratosphere and enhancing
the reflectivity of clouds. If these techniques can be proven,
each is estimated to have the capacity to neutralise the warming
expected from the current concentration of greenhouse gases. They
are both estimated to be low cost compared to sequestration and
would lower average temperatures relatively rapidly.
The fundamental difference between sequestration
and reflection, however, is that sequestration addresses the root
issue (the concentration) while reflection merely treats the symptom
(warming). Problems arising from this include:
Reflection does not address the acidification
of oceans that results from excess CO2 in the
atmosphere being absorbed by the sea;
Schemes that inject particles into the
atmosphere are likely to alter the distribution of rainfall and
also cause some reduction in the global quantity of rainfall (as
reflecting sunlight is not that same as reducing the CO2 concentration);
Many reflection techniques will need
to be replenished constantly over their lifetime and, if this
is not kept up, extremely rapid warming could ensue.
Even if the physical effects were considered
an acceptable near-term trade-off, the haunting concern lying
behind reflection is that its use could severely undermine incentives
for both sequestration and abatement such that fair and affordable
action on these would not be undertaken in the near term. Reflection
schemes may be low cost but if the concentration needs to be lowered
from its present level, someone will ultimately have to pay for
this. Deferring abatement and sequestration passes debt and risk
to future generations.
Recognition of the degree of climate change
risk currently being run carries profound implications. Not least
is that stopping all emissions now would not be enough to prevent
dangerous levels of warming if 350 ppm of CO2 turns
out to be as important a threshold as Hansen believes: the gases
already released would cause this. Restoration of the atmosphere
to a safe set of conditions will in any case require very significant
and sustained investment in sequestration, whatever shape the
new plan eventually takes.
The societies that spawned the activities producing
greenhouse gas emissions have spectacularly failed to manage the
risks arising from them to date. A current abatement-only plan
that leaves so much to chance, and the absence of an adequately
researched alternative plan, is inconsistent with the FCCC requirement
for precaution. It is important to acknowledge there has been
serious systemic failure and that continuing in some form of denial
would be dangerous.
The atmosphere is a life-sustaining system and
it is crucial that any new plan is developed and implemented under
the intent of stewardship and not as a geoengineered response.
Stewardship would have a primary focus on protecting and restoring
the atmosphere by reducing concentrations.
Restoration focuses on identifying the volumes
of carbon that need to be extracted from the atmosphere and allocating
the costs of achieving this. A crucial step in this process is
determining a concentration governments are willing to deem acceptablean
Accepted Concentration. This would define a total volume of greenhouse
gases above pre-industrial levels that was considered reasonable
for the atmosphere to carry on a long-term basis. Allocating each
nation a fair share of this Available Capacity would logically
be based on some metric of cumulative emissions and population.
That process would also quantify what volume
of greenhouse gases is in excess at present and allocate responsibilities
for sequestering it among nations. If governments set the Accepted
Concentration such that CO2 levels would be 350 ppm,
that would require about 35 ppm of CO2 to
be sequestered and would result in a bill for historic excess
emissions of about US$10 trillion if afforestation was used.
The United States' share of this would be similar to the US$3 trillion
in banking losses currently being absorbed, and Europe's bill
would be much the same.
Looking forward, if the atmosphere no longer
has the capacity to safely accept additional emissions on a long-term
basis, then it follows that further rights to utilise atmospheric
capacity can only be temporary in nature. Permits for temporary
storage can provide a means of reconciling protection of the atmosphere
with the time required for economies to "decarbonise",
if they are otherwise appropriately constrained. Temporary Storage
Permits would authorise additional emissions on condition that
the emitter pays to bring that carbon back down if later required.
These would be in place of Kyoto-style permits and limitations
on the storage period would be the critical discipline.
Developed countries have a financial incentive
to delay determining an Accepted Concentration and so requirements
for sequestration spending. An important countermeasure would
be for nations to agree to pay fees for temporary storage. Total
fees for new emissions (per tonne of carbon) would rise to the
cost of sequestration during a transition period.
As the cumulative emissions of developing countries
are low by any measure, they would pay no storage fees during
the transition period. All storage fees would be used to fund
sequestration projects, with proposals scored on multiple counts
to maximise available co-benefits, such as enhanced biodiversity.
Two factors make storage possible. One is the
lag between emissions being produced and higher temperatures being
felt. The other is the cooling effect provided by aerosols and
other reflective agents. However, storage capacity is limited
and a considerable proportion is already being used. The further
the system is pushed, the greater the risk of triggering feedback
Avoiding dangerous climate change will require
integrated planning across two distinct timeframes. The long-term
focus on cutting emissions and sequestering carbon involves extended
negotiations among governments and could be the enhanced role
of the FCCC.
In the meantime, a focus is needed on ways to
keep temperatures below levels that are dangerous or might trigger
significant feedback effects. If an Atmosphere Regulatory Commission
(the Commission) were also established, it could have the hands-on
role of managing the Apparent Concentration so as to present the
least risk at any time, consistent with an overarching goal of
restoring the atmosphere. It would also determine how much temporary
storage is to be made available, and for how long.
The Commission would focus on three climate
response measures: sequestration and two forms of reflectiontraditional
aerosol emissions and reflection projects. In this context, reflection
would provide a continuum of options ranging from more active
management of aerosols already being produced, through to emergency
measures involving large-scale intentional reflection projects.
It would assess climate change risk and response options, and
then weigh whether the risks and costs of proceeding with a particular
plan or intervention would lower climate change risk overall.
The Commission would first take account of the
efforts made by governments to abate and sequester. It would also
directly contract for sequestration projects itself, using the
funds derived from storage fees that would pass to it. If abatement
and sequestration efforts proved insufficient to hold the Apparent
Concentration within acceptable bounds, the Commission would need
to consider whether any reflection option would lower the overall
While the Commission need not undertake technology
research or build infrastructure, it would be the sole potential
purchaser of any reflection services. Private developers would
be excluded from operating reflection services and no tradeable
credits of any form would be recognised for reflection projects.
As a check against the Commission's monopsony power, it would
be subject to the highest degree of disclosure at all times.
Where precisely to locate the Commission is
an important question. Placing it outside the FCCC could raise
expectations that reflection options will be used, and so reduce
the incentives for sequestration. However, separation of the Commission
from the FCCC would appear to offer a considerable advantage overall.
By providing greater transparency and accountability, it would
help deter governments from favouring reflection options simply
to avoid higher cost abatement and sequestration. It would also
separate out functions that will need to operate at a faster pace
and under a different culture to that the FCCC has worked to.
Constituting the Commission will likely require
a new international treaty. The Law of the Sea provides a precedent
for more detailed regulation, whether under a UN treaty or alternative
arrangements. Reflection activities would initially be regulated
by way of two interlocking moratoria. The first would restrain
all field trials until minimum conditions necessary for these
were established and a second would cover all projects over and
above this level. Parties gaining from a reflection project relative
to other parties would compensate those that suffer losses, and
project sponsors would be liable for harm arising from any scheme.
While a number of factors make it realistic
to plan for the cooperative governance of reflection, it is important
to confront the potential for unilateral deployment and conflict
arising from its use. A clear driver for unilateral action would
be if one region were significantly affected by climate change
and felt the international community was responding too slowly.
Developing nations will in general suffer soonest from the more
serious effects of climate change. The prospect that a small group
of developing countries could deploy reflection schemes shifts
the balance of power such that the pace of climate change responses
in general will tend to better align with their preferences.
In another scenario, financial factors could
drive a group of developed countries to act independently as a
way to sideline negotiations with developing countries and simply
impose a new order. Large-scale reflection also has the potential
to be a "dual use" technology, capable of modifying
the weather of a particular region to suit one group of countries
at the expense of others. A worst-case scenario for environmental
risk would be if a number of competing weather modification projects
were to be launched in parallel, each operated independently,
with uncoordinated objectives and synergistic effects managed
on the hoof.
There is also the disturbing potential for new
arrangements to be cooperative, but at the expense of future generations.
This would not result from the reflection deployment itself, but
the absence of a linked commitment to sequester excess emissions.
Under such a scenario, developing countries would be offered a
much greater volume of enduring emission permits so long as developed
countries were excused from having to sequester their excess emissions
in the medium term.
A RESTORATION TRUST
Even if a Commission were established in a timely
manner and in full form, non-governmental organisation would play
a vital role monitoring and checking the regulator. A foundation
for successful advocacy would be the capability to monitor the
atmosphere as a whole, set thresholds for sustainability, account
for performance against these, and devise restoration plans. It
is proposed that the production of an integrated set of information
be the focus of a new entity that might be called the Atmosphere
Restoration Trust (the Trust). Its tasks would include the following:
State of the Atmosphere Reports: would
establish and then regularly update a comprehensive set of records
on the atmosphere;
An Atmosphere Restoration Plan: is required
to chart the path to an Accepted Concentration and show how the
Apparent Concentration will be managed during the transition;
Financial and Economic Analysis: would
include contributions to the ongoing design of permits for temporary
storage, and to defending the interests of future generations
from being discounted in value.
Both the Commission and entities such as the
Trust are just interim measures. Sustainable governance will require
enforcement provisions and the establishment of a supranational
regulator. This will involve the construction of a new set of
international understandings, entailing compacts in respect of
international justice, international trade, and military intervention.
The place of those negotiations needs to be considered alongside
demands arising from the overlapping issues of water, food and
fuel security, and humanitarian concerns generally.
This submission is based on the Council's publication,
Restoring the Atmosphere, August 2009.
Thank you for the opportunity to submit and
we would welcome the opportunity to provide oral evidence by teleconference.
The total concentration of all long-lived greenhouse gases resident
in the atmosphere at a particular time.
The concentration that corresponds to the radiative force acting
on the Earth due to human intervention, at a particular time.
Long Term Concentration:
The total projected concentration after sequestration of all long-lived
greenhouse gases resident in the atmosphere at a specified date
at least 100 years in the future.
A concentration governments collectively deem to be an acceptable
Long Term Concentration.
Available Capacity: The
difference between the pre-industrial concentration and the Accepted
Excess Emissions: The
quantity of emissions resident in the atmosphere that is in excess
of the Accepted Concentration.
Enduring Emission Unit:
A permit to emit a tonne of CO2 equivalent gases.
Temporary Storage Unit:
A permit to emit a tonne of CO2 equivalent gases
and the obligation to sequester a tonne of CO2 equivalent
gases at a later datepre-specified or subject to notification.
Temporary Sequestration Unit:
A credit recognising the temporary sequestration of a tonne of
CO2 equivalent gases. It expires on a pre-specified
date unless proof of continued storage can be demonstrated.
Enduring Sequestration Unit:
A credit recognising the semi-permanent sequestration of a tonne
of CO2 equivalent gases.
Storage Fee: At the time
a Temporary Storage Unit is utilised (though the release of emissions
under it), a storage fee is payable on each tonne of long-lived
greenhouse gases, according to the rate set for it by the Commission.
11 This is a measure of the concentration of all greenhouse
gases, expressed on a carbon dioxide equivalent basis, in "ppme".
Concentrations of CO2 alone are expressed as "ppm
of CO2". Back